Case Digest (G.R. No. 142985)
Facts:
The case involves the People of the Philippines as the plaintiff-appellee against Raymundo Magtibay y Bachoco, the accused-appellant. The incident occurred on September 15, 1997, at approximately 8:00 PM in Barangay Sagana, Bongabong, Oriental Mindoro. The accused was charged with the crime of rape under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659. The Information alleged that Magtibay, with lewd and unchaste design, unlawfully had carnal knowledge of Rachelle Recto y Rafal through force and threats to kill her.
During the trial, Rachelle testified that she went to a nearby store to buy cigarettes and ice, where she encountered the accused, who was staring at her. On her way home, Magtibay approached her, covered her mouth, and threatened to kill her if she screamed. He then forced her to lie down on a grassy area, removed her clothing, and raped her. Rachelle did not report the incident immediately due to fear of the accused's threats. It...
Case Digest (G.R. No. 142985)
Facts:
Incident Details
- On September 15, 1997, at around 8:00 PM, Rachelle Recto went to the store of Ka Emma Hernandez in Barangay Sagana, Bongabong, Oriental Mindoro, to buy cigarettes and ice.
- At the store, Rachelle noticed accused-appellant, Raymundo Magtibay, staring at her.
- On her way home, approximately 40 meters from the store, accused-appellant approached her, pulled her right hand, covered her mouth, and threatened to kill her if she shouted.
- He forced her to lie on a grassy area, removed her shorts and panties, undressed himself, and inserted his penis into her vagina.
- Due to fear for her life, Rachelle did not report the incident immediately. She only revealed it to her mother after discovering she was pregnant.
Medical Examination
- Rachelle was brought to Dr. Ronaldo Fetalberto, who confirmed her pregnancy through an x-ray examination.
- The medico-legal report showed signs of physical trauma, including a laceration in the labia minora and the presence of a fetus.
Defense’s Version
- Accused-appellant claimed he was bedridden due to influenza from September 14 to 19, 1997, and was at his parents-in-law’s house during the alleged rape.
- His wife, Merlyn Magtibay, and Remuel Gallos corroborated his alibi, testifying that he was ill and unable to leave the house.
Trial Court Decision
- The Regional Trial Court found accused-appellant guilty of rape and sentenced him to reclusion perpetua. He was also ordered to pay Rachelle P50,000.00 as indemnity.
Issue:
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Ruling:
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Ratio:
Credibility of the Victim’s Testimony
- The Court upheld Rachelle’s testimony as credible, noting that her failure to resist or shout for help did not negate the occurrence of rape. Fear for her life rendered her incapable of offering resistance.
- The Court emphasized that rape can occur even in non-isolated places and that the lack of resistance does not diminish the credibility of the victim’s account.
Defense of Alibi and Denial
- Accused-appellant’s alibi was rejected because he failed to prove it was physically impossible for him to be at the crime scene. His claim of being bedridden was deemed insufficient to establish his absence from the locus of the crime.
- Denial and alibi are inherently weak defenses and cannot prevail over the positive identification of the accused by the victim.
Award of Damages
- The Court modified the trial court’s award, adding moral damages of P50,000.00, consistent with jurisprudence in rape cases involving young victims.
- Accused-appellant was also ordered to provide support for the child born out of the rape, in accordance with Article 345 of the Revised Penal Code and the Family Code.
Positive Identification
- Rachelle’s identification of accused-appellant was deemed reliable. She knew him personally as a barrio mate and had no motive to falsely accuse him.
- The Court rejected the defense’s claim that Rachelle’s testimony was rehearsed, noting that minor inconsistencies in her statements did not undermine her credibility.
Presumption of Regularity in Police Procedures
- The Court upheld the presumption of regularity in the police investigation and the identification process, finding no evidence of irregularity or coercion.
Conclusion:
The Supreme Court affirmed the conviction of accused-appellant for rape, emphasizing the credibility of the victim’s testimony and the weakness of the defense’s alibi and denial. The Court also modified the damages awarded to include moral damages and support for the child born out of the rape.